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Sep 08 2014

Questions to Mayor about testing London Taxis to prove age limit would reduce pollution

 

Below are some of the questions that the MAYOR has been asked by Assembly Members over the last 3 or 4 years. He has been asked many many times about proper Emissions testing of taxis to prove that an age limit would reduce pollution and he continually sidestepped or ignored the questions

Dave

 

In the question below the Mayor admits that 2 decisions made by TFL were found to be unlawful by the High Court.

If someone in Public Office makes an unlawful decision it constitutes Misconduct in Public Office, a criminal offence.

The MAYOR COVERED THIS UP AND NO FURTHER ACRTION WAS TAKEN

Judicial review of taxi test

Question No: 1379 / 2010

Darren Johnson

I am advised that in September 2007 a judge upheld two of three complaints about TfL’s actions in removing approval for Eco-Power’s taxi emission reduction systems and ordered the systems to be reinstated. The judge apparently said “I consider that at times the Public Carriage Office has behaved in a discourteous and even quite high-handed manner in its dealings with Eco-Power”. What actions did the Public Carriage Office take to rectify the situation and apologise for its behaviour?

Answer from the Mayor

The legal dispute between TfL and Eco-Power commenced after 28 March 2008 when TfL issued a notice withdrawing authority for the installation and use of any further Eco-Power emission reduction systems with immediate effect.  This followed a conformity examination undertaken by the Energy Savings Trust on behalf of TfL of a taxi fitted with the third version of one of Eco-Power’s three systems. This action was challenged by Eco-Power through a Judicial Review.

At the hearing, TfL conceded that the withdrawal of Eco-Power’s approval had incorrectly included the two earlier systems which remained compliant. Whilst the Judge concluded TfL had acted lawfully to withdraw approval in respect of the third modified system, the decision to withdraw the approvals of the other two systems, based on the admission made by TfL at court, was quashed as being unlawful.

Following the Judge’s comments an internal review of the handling of Eco-Power’s third application was undertaken, and a more robust approvals process was introduced.

The Director of Taxi and Private Hire has apologised for the manner in which the withdrawal process was handled and, at present, dialogue is continuing with Eco-Power with regard to a further application of an emission reduction system.

Black cabs and air pollution (1)

Question No: 3985 / 2010

Darren Johnson

Will you undertake to test a random sample of 300 black cabs using the pollution reduction devices approved by Transport for London, in order to reassure Londoners that these devices are working? This test should include emissions produced in real life conditions, such as accelerating under load. It should also check the cabs against the standards set by the Energy Savings Trust when they approved the use of these devices.

Answer from the Mayor

Emissions tests at a certified emissions testing laboratory of 300 taxis would cost approximately £900,000 and there is no evidence that the conformity measures currently in place are not adequate to address any taxi abatement system performance issues.

As part of the annual licensing inspection, all taxis are subject to a thorough examination of their exhaust systems by a vehicle examiner to ensure they are installed correctly.  This includes the inspection of any additional, approved emissions reduction systems fitted to the taxis to ensure that they had been installed correctly and to ensure that they were appropriately certified. In addition, as part of the annual licensing inspection, all taxis are subject to an emissions test to the same standard as the emissions test carried out during an MOT to ensure exhaust emissions are within prescribed limits and excessive dense smoke is not emitted from the exhaust system.

All manufacturers and/or installers of the abatement systems are required to certify that certain actions had been carried out in respect of pre and post fitment checks.  This document will be checked at the annual licensing inspection and as part of the conditions of their licence taxi owners have a responsibility to keep their vehicles in good order and repair and the annual licensing inspection confirms that this is taking place.

Of the approximately 22,500 taxi licensing inspections carried out in the previous 12 months approximately 3% of the failures were attributed to Euro 3 abatement systems.

As I announced in my Air Quality Strategy last week, by April 2013 all taxis will be required to undertake two MOTs a year and an annual taxi related inspection. This will ensure that every taxi licensed by TfL will undergo at least two emissions tests a year rather than just one.

Black cabs and air pollution (2)

Question No: 3986 / 2010

Darren Johnson

Can you provide a breakdown of the increased resources which will be provided by Transport for London and the London Boroughs, as a result of your Air Quality Strategy, to stop black cabs from idling at the approximately 500 taxi ranks in the capital?

Answer from the Mayor

Specific resources for this activity have not been identified, but further discussion will take place now that Strategy has been published to develop practical and affordable approaches that will address the challenges in this area .such as changing road and ranks configurations, investigating further marshalling and fixed-fares for taxi sharing.  As well asThis will be achieved through dialogue between TfL and the boroughs as well as other interested parties such as, these discussions must engage Network Rail and train operators who are responsible for many of the ranks where these problems are most acute.

 

Taxi emissions testing (1)

Question No: 1376 / 2010

Darren Johnson

Is the testing of taxi emissions restricted to the smoke opacity test, which doesn’t reflect real life conditions where taxis accelerate whilst ‘under load’?

Answer from the Mayor

Like all diesel powered vehicles, taxis are only required to undergo an emission opacity test to standards set down by the DfT.  These are applied by the Vehicle Operator and Services Agency (VOSA) via the MoT system. However, taxis are also subject to regular on-street tests and an annual inspection.

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Taxi emissions testing (2)

Question No: 1377 / 2010

Darren Johnson

Has the Public Carriage Office ever used more rigorous tests, such as a mobile rolling road dynamometer to test all working taxis in a proper way?

Answer from the Mayor

Officers are drafting a response which will be sent shortly.

*

Taxi emissions testing (3)

Question No: 1378 / 2010

Darren Johnson

Why is no proper emissions conformity testing carried out as part of the annual and road side tests for taxis?

Answer from the Mayor

Emission system conformity testing, as set out by the DfT, is carried out as part of a taxi’s annual licensing inspection and also as part of any road-side compliance inspection.

*

Black cab pollution tests

Question No: 2803 / 2010

Darren Johnson

Do you regard the tests on air pollution from black cabs to be adequate?

 

Answer from the Mayor

Yes I do.

 

All taxis must pass an emissions test as part of their annual licensing inspection and all licensed taxis are subject to on-street compliance examinations to ensure that they continue to meet their licensing conditions, including emissions standards.

 

In addition to these measures my Air Quality strategy proposes a range of additional limits in regard to vehicle age, minimum Euro emissions standards and increased emissions testing for taxis.

 

 

 

Conformity testing for black cabs (1)

Question No: 2113 / 2011

Darren Johnson

Unlike other vehicle manufacturers, LTI are not required by law to conduct ‘in service’ emissions conformity tests because they sell fewer than 5,000 vehicles a year. The power for roadside checks was devolved from VOSA to local authorities in 2003, but these authorities have not conducted any testing. It is therefore the case that absolutely no ‘in service’ emissions conformity testing has been conducted on London taxis by any agency whatsoever. Why has this been allowed to happen and what action is to be taken?

Written response from the Mayor

All taxis are subject to an emissions test (to the same standard as the emissions test carried out during an MOT) ensuring exhaust emissions are within prescribed limits and excessive dense smoke is not emitted from the exhaust system.

Any vehicle manufacturer selling less than 5000 vehicles per annum is exempt from in-service legislative emissions conformity testing. It is for local authorities and VOSA to make their own decisions regarding the type of vehicle testing which would be appropriate.

Emissions testing to EC legislative standards can usually only be carried out at certified emissions testing laboratories although TfL carries out planned and ad hoc on-street conformity inspections of taxis and private hire vehicles by licensing enforcement teams in partnership with VOSA and the Metropolitan Police.

As part of the annual licensing inspection all taxis are subject to a thorough examination of their exhaust systems by a vehicle examiner to ensure they are installed correctly, including an inspection of any additional, approved, emissions reduction systems.

 

Conformity testing for black cabs (2)

Question No: 2114 / 2011

Darren Johnson

A constituent has been told by VOSA that they do not regard the emissions test for black cabs which is carried out at the annual inspection, as a proper ‘conformity test’? Can you contact them and confirm that this is their advice to you?

Written response from the Mayor

The emissions test carried out at the taxi licensing inspection is exactly the same as the emission test carried out at a VOSA MOT testing station. The same equipment and procedures are used as in an MOT. This procedure is fully endorsed by VOSA as meeting UK legislative requirements and also meets the legislative requirements for taxi licensing in London.  TfL will therefore contact VOSA on my behalf to understand why your constituent received an indication to the contrary.

*

 

Culpability for air pollution

Question No: 1684 / 2011

Darren Johnson

A constituent asks whether an action for corporate manslaughter could be brought against the Mayor of London over his failure to take sufficient action to stop preventable deaths from air pollution, or whether the Government would be liable within the Greater London area?

Written response from the Mayor
My Air Quality Strategy sets out clear policies to address air pollution in London over the next 20 years. These will deliver considerable health benefits for Londoners and help ensure that London meets relevant EU limit values.

With regards to bringing the suggested legal action against me, I could not be prosecuted when acting in accordance with my public function, and when making reasonable decisions on public policy.

Taxi emissions reductions checks

Question No: 1685 / 2011

Darren Johnson

Can you explain the legal basis for TfL / the Public Carriage Office approving emissions reduction equipment for taxis when EU law would normally require this to be done by a properly qualified authority such as the Vehicle Certification Agency?

Written response from the Mayor
The principle legislation which enables TfL to set conditions in respect of taxi licensing includes:

  • The Metropolitan Public Carriage Act 1869,
    ·       the London Cab Order 1934, as amended by the Greater London Authority Act 1999, and
    ·       the Conditions of Fitness, as amended.

The Vehicle Certification Agency (VCA) is the designated UK Approval Authority and Technical Service for vehicle type approval to all automotive European Community (EC) Directives and the equivalent United Nations Economic Community for Europe (ECE) Regulations.  Automotive EC Directives and ECE Regulations require third party approval – testing, certification and production conformity assessment by an independent body.  The VCA provides confirmation that production samples of a design will meet specified performance standards.

The previous Mayor of London’s Air Quality Strategy set a minimum emissions standard for licensed London taxis of Euro 3 for NOx and PM10 by July 2008.

In order to support the air quality strategy in respect of taxis the Energy Savings Trust (EST) were contracted to TfL to take forward the technical assessment, performance and testing of various designs of emissions reduction equipment. The performance testing of abatement systems could only be carried out at VCA approved and certified emissions testing laboratories.

Only following successful emissions and durability testing and endorsement by EST would TfL formally approve emissions abatement systems to be installed on licensed London taxis.

 

Question No: 1381 / 2011

Mike Tuffrey

Are you going to arrange for licensed taxis affected by the 2012 age limit as you did similarly for vehicles affected by the implementation of Phase 3 of the low emission zone: (a) a scrappage scheme; (b) discounts on new vehicles; and/or (c) an incentive scheme? If not, why not for each?

Written response from the Mayor

Officers are drafting a response which will be sent shortly.

Air Quality

Question No: 1437 / 2011

Joanne McCartney

Given the European Commission’s demand that you revise your air quality strategy and consider short term measures to improve air quality in London, what actions are you taking in respect of each of these demands?

Written response from the Mayor

The European Commission has not required any changes to my Air Quality Strategy, but rather requires the Government to adjust its plan for London by 11 June so that it includes short-term measures to reduce the risk of the PM10 daily limit value being exceeded. We are working with the Government to update their plan so that it includes the many PM10 reduction measures that were included in my Strategy which were not included in the Government’s time extension notification to the Commission, as well as details of measures we are now implementing through the Clean Air Fund.

 

Black cab inspections
Question number 0814/2011
Meeting date    23/03/2011
Question by Darren Johnson
Can you confirm that the twice yearly MOT Inspections of black cabs from 2013 will include a thorough examination of their exhaust systems by a vehicle examiner who is trained to ensure that any additional, approved, emissions reduction systems fitted to the taxis are installed correctly; that the MOT certificate will specify that the devices were installed correctly, as specified in the original approval specification; and that they were appropriately certified?

Answer by Boris Johnson
Officers are drafting a response which will be sent shortly.
Written response provided on 7 April 2011:
The process you are describing is done at the annual inspection which goes beyond a ‘normal’ MoT. The additional inspection I have introduced is a normal MoT which, includes an inspection of the exhaust system, mountings and condition of the exhaust system and silencer but does not make provision for carrying out the specific inspection of modified or upgraded exhaust components and such information will not be included on the MoT.

However, certificates relating to the installation of exhaust systems that have been modified / upgraded will continue to be required through the taxis’ annual inspection undertaken by TfL.

Mayor answers to London
Reduction in taxi emissions (2)
Question number 0702/2011
Meeting date    23/02/2011
Question by Darren Johnson
In the policies modelled for your Air Quality Strategy, what was the estimated reduction in PM10 taxi emissions for 2011 and 2015 resulting from taxi age limits being brought in for 2012?

Answer by Boris Johnson
Officers are drafting a response which will be sent shortly.
Written response received on 7 March 2011:
Specifically, due to the taxi age limit policy, PM10 taxi exhaust emissions in 2011 are expected to be 14 per cent lower and 18 per cent lower in 2015.

Mayor answers to London
Low emission taxis
Question number 0813/2011
Meeting date    23/03/2011
Question by Darren Johnson
Would you support the idea of Transport for London investing in the purchase of a fleet of low emission taxis which they could then rent to taxi drivers at a reduced rate, subsidised by advertising in a similar way to the hire bikes?

Answer by Boris Johnson
My proposed low-emission taxi fund is designed to offer a reduction on the purchase price of suitable vehicles for taxi drivers. This is a cost effective way of making an impact with the largest possible number of vehicles for a given fund size. The fund is also manufacturer and technology neutral.

If TfL were to purchase the vehicles instead, the number of vehicles involved would be considerably smaller with less environmental benefit.

Mayor answers to London
Low emission taxis
Question number 0813/2011
Meeting date    23/03/2011
Question by Darren Johnson
Would you support the idea of Transport for London investing in the purchase of a fleet of low emission taxis which they could then rent to taxi drivers at a reduced rate, subsidised by advertising in a similar way to the hire bikes?

Answer by Boris Johnson
My proposed low-emission taxi fund is designed to offer a reduction on the purchase price of suitable vehicles for taxi drivers. This is a cost effective way of making an impact with the largest possible number of vehicles for a given fund size. The fund is also manufacturer and technology neutral.

If TfL were to purchase the vehicles instead, the number of vehicles involved would be considerably smaller with less environmental benefit.

Mayor answers to London
Low emission taxis
Question number 0813/2011
Meeting date    23/03/2011
Question by Darren Johnson
Would you support the idea of Transport for London investing in the purchase of a fleet of low emission taxis which they could then rent to taxi drivers at a reduced rate, subsidised by advertising in a similar way to the hire bikes?

Answer by Boris Johnson
My proposed low-emission taxi fund is designed to offer a reduction on the purchase price of suitable vehicles for taxi drivers. This is a cost effective way of making an impact with the largest possible number of vehicles for a given fund size. The fund is also manufacturer and technology neutral.

If TfL were to purchase the vehicles instead, the number of vehicles involved would be considerably smaller with less environmental benefit.

 

The Mayor has been asked on many many occasions about proper testing of taxis

 

Taxi age limit consultation

Question No: 3481 / 2012

Jenny Jones

Did any of the 2009/10 meetings between yourself and the manufacturers of either the LTI taxi or the Mercedes Vito taxi discuss changing the taxi age limit?

Written response from the Mayor

Yes.

 

*

Taxi age limit (1)

Question No: 3482 / 2012

Jenny Jones

The Transport for London response to the consultation on exemptions to the age based limits recognises that the emissions from a taxi being used on the streets of London will vary from vehicle to vehicle depending on a variety of factors. Has any comparative test been carried out in recent years between old taxis and new taxis which were running in ordinary working conditions on London roads?

Written response from the Mayor

Officers are drafting a response which will be sent shortly.

 

*

Taxi age limit (2)

Question No: 3483 / 2012

Jenny Jones

Did Transport for London carry out any assessment of the cost of road testing all the taxis which were above the 15 year age limit to examine their actual emissions, before they were withdrawn from service?

Written response from the Mayor

Officers are drafting a response which will be sent shortly.

 

Black cabs and air pollution

Question No: 3131 / 2010

Darren Johnson

What measures for dramatically reducing emissions from black cabs did you consider but then reject on the grounds of being too expensive or too controversial?

Black cabs & air pollution: 13th October MQT briefing

Q. What measures for dramatically reducing emissions from black cabs did you consider but then reject on the grounds of being too expensive or too controversial?

Aim is to highlight how polluting black cabs are; why existing measures don’t do the job and ask Mayor why he rejected sensible and relatively cheap measures.

If the mayor refuses to list our key measures (below) then ask why not included? If the mayor includes these measures, then confirm that he regards them as too expensive, or controversial.

Mayor’s proposals
Black cabs account for over a fifth of PM10 emissions in central London.
Age restriction accounts for an eighth of the planned fall in taxi emissions in 2011 and about a third by 2015. No reduction planned from low emission, or zero emission taxis by 2015. The bulk of the reduction seems to be from a crack down on idling taxis, yet no evidence that this will be properly enforced, or will have this scale of impact.
Our key measures

    • Re-instating       the 6 monthly inspections
    • Creating       very low emission zones in London which only Euro 4 taxis could enter.
    • The       14,000 taxis fitted with emissions devices to have an annual test to       ensure that taxis meet standards set by Energy Savings Trust.

 

Q. Why haven’t you done an Environmental Impact Assessment of the

6 monthly inspections?

    • 2,898       black cabs failed their mid year pollution test in the 13 months prior to       the London Mayor abolishing the tests;
    • 6       monthly tested emissions with a machine, the replacement road side       inspections rely on someone looking at what is coming out of the tail       pipe?

 

Q. Very low emissions zones – you have plans to deal with the Central London hotspots by running low emission buses in these corridors, why not restrict entry to low emission Euro 4 taxis?

    • One       TfL officer estimated it would cost £10m for very LEZ covering CC area;

 

Q. Annual conformity tests – TfL have admitted that the devices fitted to over 14,000 London black cabs don’t actually do the job of reducing emissions, unless the cabs are running to the high standards set by the Energy Savings Trust. Why haven’t the Public Carriage Office ever tested these cabs to see if these standards are met?

    • TfL       does do an annual test, but it doesn’t test for the standards the Energy       Savings Trust set. Nor have their done any simple conformity testing to       see how much pollution is actually emitted when taxis are accelerating       under load, i.e. real life conditions.
    • Several       cabbies did their own tests on the pollution reduction devices and found       they didn’t meet Euro 3 standards. TfL rejected these tests by saying       that the working cabs didn’t meet the Energy Saving Trust standards.

 

Black cab inspections (1)
Question No: 3132 / 2010
Darren Johnson
When Transport for London approved a range of devices for reducing emissions from black cabs, the Energy Savings Trust did the testing and made it very clear that the devices only worked if fitted properly and only if the black cabs are maintained to very high standards. What specific conformity tests are carried out on black cabs each year to meet these Energy Savings Trust standards?

Answer from the Mayor
As part of the annual licensing inspection, all taxis are subject to a thorough examination of their exhaust systems by a vehicle examiner, to ensure they are installed correctly. This procedure includes the inspection of any additional, approved, emissions reduction systems fitted to the taxis. This also ensures that they were installed correctly, as specified in the original approval specification, and that they were appropriately certified.

In addition, as part of the annual licensing inspection, all taxis are subject to an emissions test (to the same standard as the emissions test carried out during an MOT). This ensures that exhaust emissions are within prescribed limits and excessive dense smoke is not emitted from the exhaust system.

All manufacturers and/or installers of the abatement systems are required to certify that certain actions had been carried out in respect of pre and post fitment checks and, as part of the licensing conditions, taxi owners have a responsibility to keep their vehicles in good order and repair.

The Energy Saving Trust has confirmed that the measures above maximise the benefit and robustness of any emissions reduction system in terms of its operation lifetime and emissions performance.

*
Black cab inspections (2)
Question No: 3133 / 2010
Darren Johnson
When black cab proprietors and members of the London Cab Drivers Club trialled the PM10 emissions reductions devices on their own cabs, they found that the cabs failed to meet the Euro 3 standards and so called for the roll-out to be suspended. The Public Carriage Office rejected this call on the basis that those tests were carried out on black cabs that had not been maintained to the standards set by the Energy Savings Trust. Has the Public Carriage Office carried out any of its own conformity testing to see if the vast majority of devices were being fitted and the cabs maintained to the Energy Savings Trust standards?

Answer from the Mayor
I refer you to my answer of 3132 /2010.
*
Black cab inspections (3)
Question No: 3134 / 2010
Darren Johnson
As a result of the court case involving one of the systems used by Eco-power, a more robust approvals process was introduced which involves rigorous conformity testing which goes beyond the annual inspection. Why has this process never been applied retrospectively to any other system?

Answer from the Mayor
Following the Judicial Review instigated against TfL by Eco Power and the conclusion by the judge that the TfL decisions in question were lawful, TfL carried out a review of its approval process in respect of Low Emissions Adaptations to identify any areas of the process which could be improved.

Three areas were identified and recommended for improving the approval process.  The actions undertaken to address those areas were: improved information on the application form; a more robust role for the Energy Savings Trust (EST) throughout the approval process; and improved communications and record keeping during the approval process.

The improved approval process was implemented for applicants seeking approval for equipment not already approved; it is not TfL’s intention to retrospectively apply this process to systems already properly approved. However, if a manufacturer of an approved system proposes amendments, the new approval process would then be used.

* Taxi and Private Hire Vehicles emissions tests

Question No: 3748 / 2010

Murad Qureshi

TfL require PHVs to undergo two MOTs per year, so their vehicle emissions are tested every six months. However, TfL requires black cabs to have their emissions tested to MOT standard just once a year. Can you please explain how this is equitable? In the pursuit of both fairness and improved air quality for London, what do you think should be done to end this discrepancy?

Answer from the Mayor

I will shortly publish my Air Quality Strategy, which will include a range of measures to reduce emissions from taxis and private hire vehicles, including requirements for testing of vehicles.

 

Age of Taxis?

Question No: 3521 / 2010

Caroline Pidgeon

If a taxi was to have a new engine installed into its existing shell, how would TfL view the age of this taxi? Is it by the age of the shell or the age of the engine?

Answer from the Mayor

My draft Air Quality strategy proposes a range of initiatives that seek to reduce harmful emissions, including possible age limits for taxis and private hire vehicles from 2012.  I will be announcing the final details of the strategy very shortly.  Once this has been announced TfL will proceed with implementing the proposals, including clearly specifying how age limits will be defined and implemented with the date the vehicle is first registered being the date by which the age limit would be measured.

GREATERLONDONAUTHORITY

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GREATERLONDONAUTHORITY

EMAIL NOTICE:
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